MONEY LAUNDERER by Kenneth Rijock
So how did I become a compliance officer in an investment firm that was later revealed to be a covert billion-dollar Ponzi scheme? And what happened after it was exposed by regulators? Let us start at the beginning. As a compliance consultant, I was often called upon to step in with little or no prior notice. One afternoon, a prominent Miami banking attorney who is a personal friend called up with a problem; he was scheduled to present a lecture on hedge fund money laundering the next morning at a conference on Miami Beach, but his firm had just ordered him to fly immediately to Argentina on urgent business. Since I am known for being able to speak at length, without notes, on most major AML topics, he asked me to take the lecture, to be presented early the next morning. If you've been reading this series since its inception in 2006, you know what my answer was; yes, of course. I took the offer as an intellectual challenge to be accepted.The programme organiser was a group from New York, and the conference took place at a boutique hotel on Collins Avenue. Arriving at the venue, I noticed that I knew one of the attendees, the director of compliance at a major investment firm located in Fort Lauderdale. She was there with the company's CFO, who was a certified public accountant .
The in-house presentation to company staff was well received by management, and my relationship with the company began:
- As a result of that visit, I was engaged as a compliance consultant for certain specific enhanced due diligence projects involving large investments being made by individuals. My job was to ascertain the level of risk posed by these prospective clients, and to advise if my investigation revealed information that made them unacceptable risks as clients.
- One day, I was urgently called to the company headquarters with a priority enhanced due diligence assignment. A major new client was interested in investing $15m with the firm. The company's outside compliance counsel, a major law firm, had passed upon the suitability of the client, but the firm's owner wisely reached out to me for a second opinion. He asked me to take a close look at the client and the transaction, as it was about to be approved and processed, and he wanted to be sure. He was puzzled by the fact that the investment was to be made through a Gibraltar corporation, though the client, who was a Russian national, was employing a financial services professional who was located in Switzerland.
- I then undertook an enhanced due diligence investigation, and found that the Gibraltar company was owned by a Netherlands Antilles company, that was owned by the client, who had risen very quickly to a exalted position in the Russian business community. His roots, however, appeared to be in minor crime.
- The financial adviser had an unsavory history, too. Involvement in a massive billion-dollar Russian money laundering scheme, where no Russian nationals (or Europeans) have ever been charged. I do not mention it by name, but I am sure our readers can guess which one it was.
- The last straw was a photograph that I obtained, showing the client on the tarmac at an airport in Eastern Europe, greeting a prominent arrival, whom I later determined to be his patron and mentor. The passenger that he was greeting was one of the Russian Oligarchs, a reputed billionaire, whose source of wealth remains a mystery.
- I brought my research to the company owner and the director of compliance at a meeting where a red-faced bank counsel admitted that he was indeed unacceptable as a client, notwithstanding the huge amount of new business his financial adviser was dangling in front of the company.
- Based upon that success, the company asked me to put in a minimum of four hours per day, as an in-house compliance officer, handling exclusively the high-risk cases, and those requiring enhanced due diligence investigations. The owner knew about my RICO conviction, but brought me in nevertheless, due to my "unique" qualifications, and the fact that I had prevented a probable money launderer from gaining access to the firm's investments.
I was in the door; it was to be a wild ride.
Next week: Working at a firm with problems.
The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
Read more in this exciting series



